Document pB9gEEzkm1yJYwkQQ0RY8Ywwd

SUBJECT: FROM: THRU: TO: UNITED STATES ENVIRONMENTAL PROTECTION AGENCY REGION 5 77 WEST JACKSON BOULEVARD CHICAGO, ILLINOIS 60604 CLEAN AIR ACT INSPECTION REPORT Epsilyte LLC, Peru, Illinois Charles Hall, Environmental Engineer AECAB (MN-OH) Brian Dickens, Section Chief AECAB (MN-OH) File, Epsilyte LLC, Peru, Illinois BASIC INFORMATION Facility Name: Epsilyte LLC Facility Location: 501 Brunner Street, Peru, Illinois Date of Inspection: 27 July 2023 EPA Inspector: 1. Charlie Hall Other Attendees: 1. Angel Arias, Operations Superintendent 2. Trent Goodale, Health & Safety Coordinator 3. Lisa Grant, Operations Process Engineer 4. Chad Hohman, Process & Controls Engineer 5. Emily Manternach, Senior Environmental, Health, & Safety Specialist 6. Mike McClure, Mechanical Engineer 7. Phillip Miller, Health & Safety Specialist 8. Dean Tostovarsnik, Engineering Support 9. Paul Thompson, Training & Development Manager (remotely) 10. Mark Wilson, Site Manager 11. Pamela Youell, Environmental, Health, & Safety Manager Contact Email Address: pamela.youell@epsilyte.com Purpose of Inspection: CAA 112(r) inspection Facility Type: expandable polystyrene bead manufacturer Regulations Central to Inspection: 40 C.F.R. Part 68 Arrival Time: 07:55 hrs CDT Departure Time: 12:00 hrs CDT Inspection Type: Unannounced Inspection Announced Inspection OPENING CONFERENCE Presented Credentials Stated authority and purpose of inspection. Provided Small Business Resource Information Sheet Small Business Resource Information Sheet was not provided because Epsilyte is not a small business. Provided CBI warning to facility. The following information was obtained verbally from facility representatives unless otherwise noted. Company Ownership: Epsilyte became the facility's owner on November 1, 2020. Process Description: Epsilyte receives a pentane/isopentane (85% pentane) mixture by rail tank car. In a one-step process, styrene monomer is suspended in water and polymerized with heat in the presence of initiators to form polystyrene beads. After the majority of the polymerization reaction is complete, pentane is added, and the polymerization reaction is completed by additional heating. After the beads are formed, they are dried, screened, lubed, and packaged. Staff Interview: The staff interview used the RMP Program Level 3 Process Checklist as an outline and focused on questions B13.d, B13.e, D4, D5, D6-13, D16, D21, D23, D24, D26, D27, D30, D29, D31-34, D38-41, D42-46, D47-54, D55-57, D58-61, D62-66, E1a(4), E2-7, G2-5, G7, and H2. TOUR INFORMATION EPA Tour of the Facility: Yes. Data Collected and Observations: The RMP Program Level 3 Process Checklist (Appendix B) summarizes the observations of whether Epsilyte has the required documents in its Risk Management Plan. Photos were taken during the inspection. Field Measurements were not taken during the inspection. RECORDS REVIEW Before the inspection, the inspector requested the following documents: 1. Management structure in terms of RMP and who has responsibility for the different program elements and how that is documented; 2. Off-site Consequence Analysis supporting documentation; 3. Process Safety Information; 4. Process Hazard Analysis; 5. Operating Procedures specific to the covered process; 6. Lockout/Tagout procedures; 7. Training documentation on employees who operate and maintain the covered process; 8. Mechanical Integrity program procedures; 9. Management of Change written procedures; 10. Pre-Startup Safety Reviews completed in the covered process areas; 11. Compliance Audits, the two most recent audits, audit reports, findings of the audits, and how these findings have been resolved or corrected. (if applicable); 12. Incident Investigations performed for each of the covered processes, reports from the investigations, documentation on how the report findings and recommendations were addressed and resolved; 13. Employee participation plan of action regarding the implementation of the employee participation; 14. Hot work permit program/policy, examples of active permits issued for the processes; 15. Contractor policy, a list of contractors who have worked on or near the covered processes within the past two years, documentation on the safety performance and programs evaluated when selecting a contractor, work practices that control the entrance/exit or present of contractors, documentation on how applicable provisions of the emergency response program are explained to contractors; and 16. Emergency Response Plan or Emergency Action Plan. CLOSING CONFERENCE Provided U.S. EPA point of contact to the facility. Requested documents: The inspector requested and received an example mechanical integrity inspection report. Compliance Assistance: The inspector did not provide compliance assistance. Concerns: The alternate case scenario assumes that the mishandling of one rail tank car causes a break or puncture which leads to a spill. Considering that Epsilyte has had two rail tank cars at the unloading rack at one time, Hall noted that he needs to investigate whether the alternate case scenario must include the maximum quantity. DIGITAL SIGNATURES Digitally signed by CHARLES CHARLES HALL HALL Date: 2023.09.07 13:53:27 -05'00' Report Author: Digitally signed by Brian Dickens Brian Dickens Date: 2023.09.07 14:35:42 -05'00' Section Chief: APPENDICES AND ATTACHMENTS A. Digital Image Log B. RMP Program 3 Checklist APPENDIX A: DIGITAL IMAGE LOG Photographer: Pamela Yuell Camera: Due to safety concerns, Yuell used an intrinsically safe tablet with a camera. Image Date Description of Image Number 1 07/27/2023 Pentane Unloading Station Appendices Page 6 of 15 Facility Name: Epsilyte LLC Facility Location: 501 Brunner Street, Peru, Illinois Date of Inspection: 27 July 2023 Image Date Description of Image Number 2 07/27/2023 Pentane Tanks and Production Pumps Appendices Page 7 of 15 Facility Name: Epsilyte LLC Facility Location: 501 Brunner Street, Peru, Illinois Date of Inspection: 27 July 2023 Image Date Description of Image Number 3 07/27/2023 Pentane Safety System and Flow Meter Appendices Page 8 of 15 Facility Name: Epsilyte LLC Facility Location: 501 Brunner Street, Peru, Illinois Date of Inspection: 27 July 2023 Image Date Description of Image Number 4 07/27/2023 Pentane Tanks and Production Pumps Appendices Page 9 of 15 Facility Name: Epsilyte LLC Facility Location: 501 Brunner Street, Peru, Illinois Date of Inspection: 27 July 2023 Image Date Description of Image Number 5 07/27/2023 Pentane/Isopentane Flow Meter Appendices Page 10 of 15 Facility Name: Epsilyte LLC Facility Location: 501 Brunner Street, Peru, Illinois Date of Inspection: 27 July 2023 Image Date Description of Image Number 6 07/27/2023 Pentane sensor (right) and Styrene sensor (left) Appendices Page 11 of 15 Facility Name: Epsilyte LLC Facility Location: 501 Brunner Street, Peru, Illinois Date of Inspection: 27 July 2023 Image Date Description of Image Number 7 07/27/2023 One of three Pilot Plant Reactors. Appendices Page 12 of 15 Facility Name: Epsilyte LLC Facility Location: 501 Brunner Street, Peru, Illinois Date of Inspection: 27 July 2023 Image Date Description of Image Number 8 07/27/2023 Building 4, 5th Floor, Top of Reactor 14. Appendices Page 13 of 15 Facility Name: Epsilyte LLC Facility Location: 501 Brunner Street, Peru, Illinois Date of Inspection: 27 July 2023 Image Date Description of Image Number 9 07/27/2023 Entrance of Pentane Pipe into Building 4. Appendices Page 14 of 15 APPENDIX B: RMP PROGRAM 3 CHECKLIST Appendices Page 15 of 15